DCH 96 The People's Dispensary for Sick
Animals
c/o Francene Graham,
Committee Assistant
to the Joint Committee
on the Draft Charities
Bill
Scrutiny Unit
Room G10
7 Millbank
LONDON
SW1P 3JA
18 June 2004
Dear Sirs,
I am pleased to
enclose the PDSA submission to the Joint Committee on The Draft
Charities Bill. PDSA welcomes the updating of laws governing
charities and supports the intention to improve the regulation
of the charitable and wider not-for-profit sector.
In particular,
PDSA welcomes the addition of 'the advancement of animal welfare'
to the list of purposes of charity and thanks those who have responded
to our concerns in this regard.
For PDSA the challenge
remains to extend existing charitable services to all those in
need of its help, without compromising the volume and quality
of the services offered to existing clients. However, just to
stand still, PDSA, like many other national charities, faces a
funding dilemma. Participation in charitable giving is known
to be in decline and the proliferation of charities means greater
competition for donors. The control of costs therefore is paramount
and PDSA is concerned by any increased regulation that results
in additional bureaucracy and therefore higher administrative
costs, without any proportionate benefit to public trust and confidence.
As a charity with
177 shops, PDSA endorses the response of the Association of Charity
Shops. In particular, it shares concerns about the specific notification
requirements set out in section 66 C (2) of the draft Bill requiring
notification of the precise day or dates and locations of each
collection to local authorities at least 14 days and no more than
6 months in advance. The adverse impact of such detailed regulation
would be significant for charitable retailing and would result
not only in reduced charitable service provision but also in reduced
opportunities for poor people to purchase goods at low prices
from charity shops.
Should you wish
to further discuss any aspects of the PDSA response I would be
extremely happy to do so. I would also welcome the opportunity
for PDSA to continue to be involved in the process by which these
proposals are enacted into legislation.
Thank you for your
consideration of our concerns.
Yours faithfully
Marilyn Rydström
Director General
PDSA submission
to Joint Committee re The Draft Charities Bill
Introduction
1. PDSA is Britain's
leading veterinary charity, caring for the pets of needy people
by providing free veterinary care to their sick and injured animals
and promoting responsible pet ownership. The charity provides
over one million free treatments every year, equivalent to PDSA
vets and nurses seeing 4,500 sick and injured pets every working
day. In 2004 the total cost of providing this PetAid service
will reach £33 million.
2. One of the key
ways in which PDSA raises awareness of its work and generates
income for this work is through its network of 177 charity shops.
It is difficult to quantify the impact of the shops on awareness
but in 2003 the shops made a net contribution of £1.8 million
to the cost of delivering PDSA PetAid services.
3. In England and
Wales PDSA operates 142 charity shops. All are entirely dependant
on donated goods and, while some stock is donated directly to
the shops, most is collected via a sack collection scheme. In
England and Wales the charity operates a fleet of 56 vans solely
for this purpose. Sacks are distributed through letterboxes and
later sacks full of donated goods are collected from doorsteps.
4. Like those of other
charities, PDSA shops play an invaluable role in reusing and recycling
unwanted textiles and deliver a vital social benefit to those
on low incomes, including the unemployed, pensioners and students.
The draft Bill
5. PDSA welcomes
the addition of 'the advancement of animal welfare' to the list
of purposes of charity.
6. PDSA also welcomes
the inclusion of the 'Charitable Incorporated Organisation' (CIO)
and the opportunities this offers for reduced bureaucracy.
7. PDSA is not
concerned at the omission of the recommendation in the Strategy
Unit consultation paper, Private Action, Public Benefit, that
charities should be able to trade as part of their normal activities
without the need to set up a trading company. The charity considers
that the existing system has a number of advantages, in particular
in protecting charitable activities from trading risk, and therefore
that charities were unlikely to change their current mode of operation.
8. PDSA welcomes
the acknowledgement in the draft Bill that sack collections of
purely donated goods do not pose significant issues of public
trust, confidence or capacity and the removal of such collections
from the licensing regime is similarly welcome.
9. However, PDSA
considers that the benefit of this de-regulatory measure is totally
negated by the specific notification requirements set out in section
66 C (2) of the draft Bill. These require notification of the
precise day or dates and locations of each collection to local
authorities at least 14 days and no more than 6 months in advance.
This takes no account of how these collections are organized
and for charities such as PDSA is unworkable. The requirement
will result in significant administration costs and may even result
in shops running out of stock, thereby reducing income.
10. To give an
idea of the scale of the problem to be faced by PDSA. In an average
week in England and Wales PDSA distributes in the region of 62,000
pink sacks (the PDSA collection device). This represents just
over 1,100 sacks per van and, at an average of 250 to 300 sacks
per collection, about four collections per van per week; in total
around 220 collections every week. To administer such a scheme
across England and Wales may well require the equivalent of two
or three additional members of staff as well as possibly resulting
in centralization of this activity, a significant change from
the local organization now in place. This is contrary to the
intentions of the Draft Bill and certainly falls into the 'increased
regulation, additional bureaucracy, higher administrative costs
and no proportionate benefit to public trust and confidence' category
referred to in my letter.
11. The charity
considers there will be a similar increase in costs for local
authorities and other charities with retail networks.
12. PDSA also considers
the new penalty of a fine of up to £1,000 for failure to
notify for each offence to be excessive.
13. PDSA supports
the need for local authorities to know which charities are collecting
in their areas so that they can focus their attentions on unauthorized
collections but considers this can be achieved by a simple annual
notification by charities collecting goods house-to-house that
they will be collecting in the area giving details of the approximate
frequency or scale of collections along with details of the purpose
of the collections, their general location and the details of
the organizer. This would enable local authorities to maintain
a register of authorized collections that could be referred to
if there was a cause for concern.
Amendment sought
14. PDSA therefore
requests that an amendment to paragraph 66 C (2) of the draft
Bill be considered so that the notification required for the collection
of goods house-to-house by charities to local authorities should
be made only on a periodic basis (e.g. annually) and in more general
terms as regards timing/frequency and location. It should not
be required for every individual collection.
PDSA, Whitechapel Way,
Priorslee, Telford, Shropshire TF2 9PQ
18 June 2004
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