Consultation Response Form 

Statutory Guidance for Local Authorities: Local Toilets Strategies 

Please return this form to reach the Welsh Government no later than 4 April 2018. The email address for responses or queries is:  

LocalToiletsStrategy@gov.wales 

Postal responses should be sent to: 

Telephone contact for enquiries: 03000 253240. 

This form can be downloaded from the Welsh Government consultation webpage here: 

https://consultations.gov.wales/consultations/local-toilets-strategies-statutory-guidance-local-authorities

Your name:	Jane Lee
Organisation (if applicable):	Abergavenny Town Council
Email Address:	clerk@abergavennytowncouncil.gov.uk
Telephone Number:	01873 735820
Your address:	Town Hall Cross Street Abergavenny NP7 5HD

Responses to consultations may be made public – on the internet or in a report.  If you would prefer your response to be anonymised, please tick here:

Question 1:  Is the process for consulting, preparing, publishing and reviewing a local toilets strategy clear?   The Town Council has significant reservations regarding the purpose of such a strategy if the local authority does not have to provide toilets. We are concerned that expectations may be raised if the assessment identifies a need which the local authority is unable to meet. Conversely, there is concern that if the assessment indicates that toilets are not of a suitable standard then this may result in closure which reduces toilet provision in the area. There is no requirement for local authorities to make improvements to toilets to improve the standard of provision.   It is not clear if local authorities have to submit their strategy to Welsh Government.

Question 2:  Is there enough guidance on longer term thinking to shift the focus towards finding sustainable solutions?   As there is no additional funding associated with this requirement the default position will be that toilet provision will be dictated by short term funding decisions.

Question 3:  Is there enough guidance on integration to enable the mainstreaming of toilets for public use within wider local policies?   Please see answer to Q1 re the importance of the Town & Community Council sector. This sector is more than a sector who should be involved in the consultation.

Question 4:  Is there enough guidance on involvement to allow for the needs of the local and visiting population to be properly assessed?    There is concern about the capacity in local authorities to undertake these assessments in the manner set out in the guidance.

Question 5:  Is there enough guidance on collaboration to enable partnership working and encourage shared solutions?

Question 6:  Is there enough guidance on prevention to focus local toilet strategies to prevent problems from occurring or getting worse? This area of the guidance relies very much on funding being available

Question 7:  Are there any significant gaps in the current draft guidance?   The guidance does not adequately reflect the importance of the Town and Community Council sector in directly managing or providing funding to local authorities to ensure that toilets remain open. Abergavenny Town Council makes a significant payment to Monmouthshire County Council to ensure that the toilets in the town remain open.

Question 8:  Is the design of the National Toilet Logo fit for purpose?

Question 9: We would like to know your views on the effects that the Statutory Guidance on Provision of Toilets in Wales: Local Toilets Strategy would have on the Welsh language, specifically on opportunities for people to use Welsh and on treating the Welsh language no less favourably than English.? ?  What effects do you think there would be?? How could positive effects be increased, or negative effects be mitigated??

Question 10: Please also explain how you believe the draft Statutory Guidance on Provision of Toilets in Wales: Local Toilets Strategy could be formulated or changed so as to have:   – positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language, and   – no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language.? ?

Question 11: We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them: ? Please enter here:   It would be interesting if the amount of Public Facilities Grant Scheme by local authority that is now incorporated into the Revenue Support Grant could be published. Also of interest would be details of local authorities that charge for toilets and the range of charges.

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